Privacy Policy

    Last updated on 24/01/2024 in Paris

    At Nara, we take your privacy seriously. This privacy policy explains how we collect, use, share and protect the personal information of our application's users.

    We may update this privacy policy from time to time. When we make significant changes, we will inform you by email or via a notification in the app.

    1. Information collected

    The term "Information" refers to data that may include, without limitation, personal data. Nara collects information that you share with us directly (data you share with us) and also as part of your use of our services (data we collect as part of your use of our services).

    1.1 Data you share with us

    Account creation data:

    this is the data required to create an account, without which we cannot offer you our Services: your email address, your first and last name, your date of birth and a username.

    When creating your account, you may also choose to share certain additional information with us: a profile photo.

    Content data:

    We receive the content you create when using our Services. This includes: photos, videos, captions and geolocation data.

    Communications with Nara:

    When you report an issue with our services, respond to a survey, request assistance or exercise your rights, we receive from you the information necessary to help you, respond to you and improve our services. This includes: photos, videos, copies of government-issued identity documents, identifiers (email addresses) or other information.

    1.2 Data we collect as part of your use of our Services

    Like all internet services, when you use our Services we automatically receive information about you through your device and your use of our Services:

    Technical and connection data:

    IP address, account creation date, last login, equipment and connection point.

    Interaction data:

    Sending and cancelling friend requests to other users, interactions with content.

    Usage data:

    Friends list, number of friends, actions performed, journeys taken, number of photos and videos uploaded, content viewed, deletions, app crashes, event logs and any other data resulting from your use of the application.

    Device and equipment data:

    device type, operating system version, preferred language and applications.

    We also receive data when you choose, if you wish, to use certain features of our services:

    Cameras and photo library:

    You can create an account without allowing us to access and collect data from your device's camera or photo library. However, you will not be able to add content to memories you create or in which you are tagged.

    Geolocation data:

    You may choose not to share your location when creating an account through our Services.

    Contact list data:

    You may choose to allow Nara to access your contact list in order to identify contacts who may have already created a Nara account. We do not access your contact list without your permission. If you choose to find your friends by giving us access to your contact list, we analyze the phone numbers in your contact list (we do not view anything else), securely transmit these analyzed phone numbers to our systems, compare these analyzed numbers to the list of analyzed phone numbers of other Nara users, and return the username as a friend suggestion.

    We are committed to using this data responsibly and transparently, in accordance with applicable data protection laws and regulations. Our goal is to continuously improve the user experience while preserving your privacy and the security of your information.

    2. Use of collected information

    We use your information carefully and thoughtfully in order to offer you our Services.

    We are able to offer our services thanks to a variety of software and technical infrastructure. It can be complex to understand how these systems work, and they also evolve constantly as we improve our services. Often, information is used by several parts of the system to deliver even a single feature. Generally speaking, Nara uses the information it receives for the following purposes:

    Operating, improving and providing our Services:

    creating your account, receiving and displaying content, identifying content or accounts that may interest you, ensuring our services work correctly and improving these services.

    Security and safety:

    ensuring your safety and that of other users, the security of our services and our partners, as well as compliance with applicable laws and regulations.

    Assessment and analysis:

    assessing the effectiveness of our Services, including the application's performance (e.g. crashes and their causes), its stability, and your use of the application's features.

    Communications:

    We need to use your information to contact you as part of the development of our services, certain features such as changing your password, or when you contact us via the application to ask a question.

    Why we process the dataWhich personal data is processedLegal basis for processingRetention period
    To create your account and identify you when logging in.Mandatory profile data (last name, first name, username and email address) and optional profile data (profile photo)Performance of the contract between you and Nara.Duration of your use of the services or until you request deletion of your account.
    To provide you with the services.Data related to devices and equipment used.Legitimate interest of the data controller in providing a functional application.Duration of your use of the services or until you request deletion of the data.
    To process requests, complaints and reports.Content data, communications with NaraLegitimate interest of the data controller in providing a functional applicationDuration of your use of the services.
    To assess the performance of the Nara application.User usage and interaction data on the applicationLegitimate interest of the data controller in providing functional improvements to the applicationDuration of your use of the services or until you request deletion of the data.

    3. Sharing and disclosure of collected information

    We only share your information when it is necessary to provide our Services or when required by law. In general, this covers the following cases.

    Nara employees:

    authorized Nara employees may need to access your information in order to provide you with our Services and related support.

    Other users:

    when you share Content through our Services, it is visible to your friends or your friends' friends, depending on the privacy level chosen by the creator of the memory in which you share your content.

    Service providers:

    in order to provide you with our services, we work with a limited number of service providers. These partners are notably responsible for technical support and hosting, sending notifications, publishing and sharing content, user analysis and satisfaction surveys, and managing security incidents or fraudulent activity, among others. As part of our collaboration with these partners, we may share your information with them in order to provide our services to you.

    Partner integrations:

    when we collaborate with a partner to offer you a feature, we may share your information with the partner in order to integrate that feature into our services. We are particularly careful in selecting the third parties with whom we share your data. We ensure that these third parties are committed to protecting your personal data in the same way we are.

    Legal and regulatory obligations:

    we may occasionally receive legal requests for information about our users, may need to proactively share data with authorities when we become aware of certain content on our services (for example, child sexual abuse material or terrorism), may need to respond to fraud or security questions, or may need to protect people on our services or elsewhere from harm.

    Change of ownership:

    In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, Nara may share, sell or transfer information. This Privacy Policy applies to all information transferred.

    4. Data retention period

    Account creation data:

    retained indefinitely (i.e. for as long as your account is active) to the extent necessary for the creation and management of your account. If you choose to delete your account, this information will be deleted.

    Content data:

    retained indefinitely (i.e. for as long as your account is active) or until you delete the Content.

    Technical and connection data:

    retained for a period not exceeding 24 months. However, certain connection data also relates to account creation data and is retained in accordance with the retention periods for that data.

    Interaction data:

    retained indefinitely (i.e. for as long as your account is active) or until you delete the interaction.

    Usage data:

    retained for a period not exceeding 24 months.

    Device and equipment data:

    retained for a period not exceeding 24 months. However, certain connection data also relates to account creation data and is retained in accordance with the retention periods for that data.

    Cameras and photo library:

    content data is retained indefinitely (i.e. for as long as your account is active) or until you delete the Content. As a reminder, we do not upload all your photos and videos — only content you upload and share is collected.

    Geolocation data:

    when you share your geolocation data, this information is retained for as long as the Content remains in our system (i.e. until you delete the Content or your account).

    Contact list data:

    the phone numbers we retain are encrypted and are only used to help you find your friends. This information is retained indefinitely (i.e. for as long as your account is active) because it is essential for us to be able to provide and manage your account.

    5. Control over collected information

    Notifications:

    you can choose and control the activation or deactivation, in your phone's settings, of the notifications you receive relating to our Services.

    Privacy of published content:

    you can change the visibility level of the content you share on our services. This can be managed at any time in the settings of each memory in which you are tagged.

    Modifying personal information:

    you can change your last name, first name, username and profile photo directly from the application settings.

    Account deletion:

    in the application settings, you can choose to delete your account at any time. If your account is deleted, we will retain account creation data to prevent other users from creating an account with the same information. Once your account is deleted, we delete all the content you have shared and all interactions you have had on the application.

    6. Contact

    For any question or concern regarding this policy or your data, please contact us at: